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Hurley v. Eddingfield

Indiana Supreme Court
59 N.E. 1058 (1901)
ELI5:

Rule of Law:

A physician's state-issued license to practice medicine is merely a permission to practice, not a mandate, and it does not create a legal duty to accept any patient who seeks their services.


Facts:

  • Dr. Eddingfield was a licensed, practicing physician and had previously served as the decedent's family doctor.
  • The decedent became dangerously ill and sent a messenger to summon Dr. Eddingfield.
  • The messenger informed Dr. Eddingfield of the decedent's violent sickness, tendered payment for his services, and explained that no other physician was available in time.
  • The decedent relied on Dr. Eddingfield for medical assistance.
  • Dr. Eddingfield was not occupied with other patients and could have attended to the decedent.
  • For no stated reason, Dr. Eddingfield refused to render aid.
  • The decedent died as a result of the lack of medical attention.

Procedural Posture:

  • The appellant, as administrator of the decedent's estate, sued the appellee (Dr. Eddingfield) in a trial court for wrongful death.
  • The appellee filed a demurrer to the complaint, arguing that it failed to state a legally sufficient claim.
  • The trial court sustained the demurrer, effectively dismissing the appellant's lawsuit.
  • The appellant appealed the trial court's decision to sustain the demurrer to the Supreme Court of Indiana.

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Issue:

Does a licensed physician, who has previously served as a patient's family doctor, have a legal duty to render aid to that patient when they become dangerously ill and no other medical help is available?


Opinions:

Majority - Baker, J.

No. A physician's refusal to enter into a contract of employment does not constitute a wrongful act giving rise to liability. The state's licensing act for physicians is a preventive measure to ensure qualification, not a compulsive one that forces a doctor to practice or accept any particular patient. Unlike common carriers or innkeepers who have a duty to serve the public, a physician is free to contract for their services on their own terms, and no legal duty arises before a doctor-patient relationship is voluntarily established.



Analysis:

This case establishes the foundational "no-duty-to-treat" principle in American medical jurisprudence. It firmly places the doctor-patient relationship within the domain of private contract law, where mutual assent is required to create a duty of care. By rejecting the analogy to public-service entities like innkeepers, the court solidified the status of physicians as independent professionals free to choose their patients. While this core principle remains, it has been significantly modified by subsequent anti-discrimination laws and statutes like the Emergency Medical Treatment and Active Labor Act (EMTALA), which imposes a duty on hospitals to treat patients in emergency situations.

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